Coping With Confusing Label Language

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From time to time, we all scratch our heads while reading pesticide labels that seem to contradict themselves, or that don’t make it clear what we can or cannot do with a product. Consider these pairs of seemingly contradictory statements from labels of commonly used pesticide products. (Disclaimer: The purpose of this article is to be useful, not to bash on the valued manufacturers that supply us with the pesticides we need! Thus, these examples have been altered slightly in order NOT to disclose the identities of any products or manufacturers.)

“Do Not Use In Food Plants.”

“May Be Used In Non-Food Areas Of Food Plants.”

“Do Not Apply In Kitchens.”

“Apply Inside Of Floor Drains.”

“Do Not Apply This Product To Furniture.”

“Apply To Tufts, Folds And Around Buttons Of Upholstered Furniture.”

How is it possible that a pesticide manufacturer, which may employ an entire regulatory-compliance department staffed by lawyers, can write such double-speak? Are they trying to mislead us? Assuredly, they are not:

Many seemingly contradictory statements are the result of “boilerplate” verbiage used by more than one manufacturer and/or for multiple pesticide labels; since EPA has approved a statement once, there is a tendency to lift that exact language from one approved label and use it on another product’s label, but with conditions and qualifiers attached later in the description.

Sometimes a smaller manufacturer might have a wonderful product to offer, but does not have the wherewithal to employ a roomful of English majors and attorneys to write their labels. So, they have borrowed language they know has been approved elsewhere and will likely be approved again on their own products.

In other instances, a manufacturer might have been going back and forth with EPA for some time, trying this language and that language until the text that finally wins approval is bogged down with exceptions.

Whatever the cause of confusing labels, they can create frustration among PMPs who want to use products in a legal manner while achieving good results — but for the life of them, cannot figure out what the label says! So, what are we supposed to do?

There are several ways to respond to a difficult-to-understand label:

READ THE LABEL CAREFULLY. Maybe the confusing label language is fully explained in the next sentence or elsewhere on the label.

LET GOOD SENSE PREVAIL. Most of the time, you can figure out what the confusing language really means. For example, the product whose label directs us not to apply it to furniture — and then turns around and tells us how to apply it to furniture — is providing an exception that allows the otherwise prohibited use pattern. Go ahead and use the product, and make sure that your application record clearly shows that you followed the restrictions.

ERR ON THE SIDE OF CAUTION. Maybe we should use that product whose label instructs us not to apply it in kitchens, but allows use in floor drains in drains in areas other than kitchens.

WHEN IN DOUBT, CALL THE MANUFACTURER. Most larger pesticide suppliers have regulatory-compliance specialists who can clear up foggy label directions for you. In fact, you may be doing them a service by asking; they might amend future versions of the label to be more clear.

WHEN STILL IN DOUBT, CALL YOUR STATE’S REGULATORY AUTHORITIES. In some cases, you might want to check with someone in your state’s pesticide lead agency and get their interpretation of a fuzzy label. Write down the date of the call, the name of the person you spoke with and what he or she said. Believe it or not, state pesticide inspectors are interested in helping PMPs use pesticides properly, not in “catching us in the act” of misapplying materials.

When really, really in doubt, you could always hire some English majors — with advanced law degrees — but that may be a stretch!

The author is chief technical adviser at Plunkett’s Pest Control, Fridley, Minn., and a member of the Copesan Technical Committee. He can be reached at jbruesch@gie.net.

Copesan is an alliance of pest management companies with locations throughout North America. To learn more, visit www.copesan.com.

News & Notes

Bed Bug Supplement - Bed Bug Supplement

BedBug Central Releases Results from June Survey

LAWRENCEVILLE, N.J. — BedBug Central announced results from its June survey, and as anticipated, June brought an increase in bed bug activity in many of the regions across the United States.

BedBug Central’s Jeff White said the June findings are consistent with seasonal fluctuations with bed bug activity that have been observed since the resurgence of these pests around 2005. “It has been well documented by many different researchers and bed bug experts that bed bug activity in residential settings increases in the summer months, specifically July, August and September.”

Knowing this, BedBug Central expected to see an increase in June bed bug activity; although the Mountain Time Zone (region 5) and West coast (region 6) appear to be lagging behind with an increase in bed bug activity.

White said, “An interesting observation moving forward will be to note whether this is an anomaly in the data or this is a seasonal trend we note each year (stay tuned to next year’s survey results).”

Another interesting observation for White was that several companies based largely in hospitality were “up significantly” in June. “We find this observation interesting and the question it raises is whether or not vacation season drives bed bug activity,” he said.

As for the quarterly analysis, Regions 5 and 6 were slow all quarter compared to the rest of the U.S. The Southeast and traditional Midwest (regions 2-4) were busy most of Q2 and no slowdown appears in sight. The Northeast (region 1) had a minor slowdown in May but companies reported it being busy again in June. “We expected the busy trend to continue for regions 1-4 and will monitor regions 5 and 6 to see if the slow/flat spell stops and bed bug activity picks up for more companies located in those regions,” White said.

EPA Releases Updated Bed Bug Efficacy Guidelines

WASHINGTON, D.C. — In June, EPA announced the availability of a final test guideline, “Laboratory Product Performance Testing Methods for Bed Bug Pesticide Products; OCSPP Test Guideline 810.3900.” The guideline provides recommendations for the design and execution of laboratory studies to evaluate the performance of pesticide products intended to be effective against bed bugs.

The guidance also includes directions for data reporting. This guidance applies to products to be applied for a pesticidal purpose such as to attract, repel or kill bed bugs. It does not apply to repellent products applied to human skin, and does not apply to products exempt from Federal Insecticide, Fungicide and Rodenticide Act registration under 40 CFR 152.25.

EPA’s test guidelines are intended for use in the testing of pesticides and toxic substances and development of data for submission to the EPA. The test guidelines are organized by series number Final Test Guidelines for Pesticides and Toxic Substances.

Under FIFRA, all companies wishing to register a pesticide product for use against public health pests, such as bed bugs, must submit pesticide product performance data that demonstrate that the pesticide product works against the pests for which the product is intended.

Dini Miller Named a ‘Healthy Homes Hero’

Miller

BLACKSURBG, Va. —Dini Miller, urban pest management specialist for Virginia Cooperative Extension, was named the first “Healthy Homes Hero” by the Department of Housing and Urban Development, the Augusta Free Press reported.

The award stems from HUD’s ongoing efforts to discuss ways to improve life in the HUD community during National Healthy Homes Month in June.

Miller has worked on pest control in public housing, focusing on cockroaches, bed bugs and allergens that come from pests. She is currently working on a checklist of standards for pest control contracts in HUD buildings to ensure extensive care.

Australia’s Doggett Interviewed for Podcast

SYDNEY — Stephen Doggett, director of the Department of Medical Entomology at Westmead Hospital in Sydney, Australia, was recently interviewed about bed bugs as part of the popular Australia Float Your Boat podcast.

As part of the interview Doggett previewed his forthcoming bed bug academic text Advances in the Biology and Management of Modern Bed Bugs, due for release in 2018. The book is edited by Doggett, along with entomologists Dini Miller and Chow-Yang Lee, and includes more than 50 contributors from all over the globe.

Four-Point Plan

Bed Bug Supplement - Bed Bug Supplement

Dr. Stephen Kells has created a handy reference PMPs can use to eradicate bed bugs from multifamily housing.

Editor’s Note: The following article was adapted from the webinar “Bed Bug Control Starts With Good Contracts” presented by StopPests in Housing, a Northeastern IPM Center program funded by an interagency agreement between HUD’s Office of Lead Hazard Control and Healthy Homes and the USDA. For more Integrated Pest Management (IPM) resources and training opportunities visit stoppests.org or email stoppests@cornell.edu.

Pest control companies have been busy eradicating bed bugs since the problem spiked in the United States about 10 years ago. There are numerous approaches to killing bed bugs and if done properly, the problem should go away.

Dr. Stephen Kells, an urban and structural pest entomologist and associate professor at the University of Minnesota, asked the obvious question: Why do we still have bed bug problems?

“We’ve figured out how to kill bed bugs,” said Kells, who’s been studying and working with bed bugs since 2001. “The issue is how can we make it faster, cheaper and safer? Part of that is we’re not being thorough enough when addressing infestations.”

The research on the biology and behavior of bed bugs has yet to catch up with the infestations, Kells said. So, it’s up to PMPs to provide a foolproof pest management protocol.

In March 2016’s StopPests in Housing webinar, “Good Bed Bug Control Starts with Good Contracts,” Kells provided four key points every pest management professional should address if they don’t want to “chase the problem” throughout multifamily housing.

#1: THE PLAN. Kells said it’s not enough to get rid of the problem. PMPs should take extra steps to ensure the problem never recurs. How to do that requires a meticulous plan and substantial knowledge of bed bug behavior.

Bed bugs travel, and in multifamily housing, Kells said an infestation can easily multiply with different tenants traveling and creating more pathways.

“Something as simple as checking the surrounding rooms above or across the hall is automatically a program,” Kells said. “As you find new infestations, you’re progressively checking the surrounding rooms.”

When treating the infestation with pesticide, Kells said landlords and tenants should understand that their PMP should be using all three forms: residuals, contact insecticides and dust formulations. If it’s a heat treatment, PMPs should apply insecticide in the unheated areas.

#2: BIOLOGY. The public’s perception of bed bugs and what they are, are two different things, said Kells. That is why if you receive a bed bug complaint, it’s essential you confirm that it’s truly a bed bug infestation. Bat bugs are frequently confused for bed bugs due to their similar shape.

Though bat bugs do not feed on humans, bed bugs do. Never use someone’s bites as proof; bed bug bites look like flea bites, and poison ivy, to name a few.

#3: TRACKING COMPLAINTS. Bed bugs are never limited to just a bed. And they aren’t limited to only a kitchen or a bathroom either. Where the tenant (and their visitors) goes outside can affect how infestations occur and spread. “Bed bugs are specialists in living next to people,” Kells said. “Their droppings and pheromones allow them to ‘stay underneath the radar.’”

Kells’ advice is to not be naïve that the complaint you received is the only known bed bug problem in the building. He cited an example of an apartment that has a heavy infestation of bed bugs, and one bed bug spreads into the apartment next door. If the apartment that has the one bed bug complains and you eradicate it, there’s still that other infestation that puts the rest of the apartments at risk.

“If we just respond to complaints, we’ll always keep coming back,” he said.

#4: COMMUNICATION. People usually do not care about bed bugs until they experience an infestation, said Kells. It’s the PMP’s job to inform customers about bed bugs and the way they’re treated before a problem occurs. If they are knowledgeable, then landlords and tenants will call or shy away from DIY bed bug treatments.

Customers who cannot read English or speak little English pose a challenge for PMPs in properly communicating with or teaching tenants about bed bugs. As a result, Kells suggested translated preparation sheets, pictograms or finding help through social services.

“We found a lot of people who were limited English proficient were reluctant to report anything because they were afraid they were going to be kicked out of their apartments,” Kells said.

Between property management, tenants and pest control, Kells said there is a lot of room for blame. But it’s important for all parties to communicate or else the bed bugs win.

Baits: An ‘Outside-the-Box’ Bed Bug Solution

Bed Bug Supplement - Bed Bug Supplement

“Bed bug research” is an all-encompassing three-word description for one of the industry’s busiest and most important academic focuses of the last 10 to 15 years. While there are always research projects underway for all types of insects at entomology departments throughout the country, bed bug studies and research have dominated the conversation the past decade, just as they have in the consumer media.

The research has revolved around everything from resistance to new formulations to behavioral studies. A not-so-new research project that has been in the works for about six years could ultimately change the entire way pest management professionals treat for and prevent bed bugs.

Zachary DeVries, a doctoral student at North Carolina State University, is part of a team of researchers that includes Dr. Alvaro Romero (New Mexico State University), Angela Sierras (N.C. State University) and Dr. Coby Schal (N.C. State University), that is conducting research in an effort to create an effective bed bug bait.

Baits are common tools for fighting certain pests, such as termites, rodents, ants and cockroaches. But bed bugs have never had to circumvent a bait because the industry has been dominated by the use of pesticides, heat treatments, green or natural products, and fumigation methods.

“We wanted to think of ways that were a little different. So, we started to look at other urban pests (termites, ants, cockroaches) and the most effective and balanced tool for safety seems to be baits, where you bring the pest to the active ingredient (AI) and eliminate it using a small amount of insecticide,” DeVries said. “So, we thought of that and focused our attention on ‘What do we need to do to build a bait?’”

So, the development of a bed bug baiting system began. The benefits? Baits are easy to use; offer a long-lasting residual; target specific sites; pests are less resistant to them; and they kill using less active ingredient than other products.

Three things are needed to build a bed bug bait: an attractant, a feeding stimulant and an active ingredient.

Zach DeVries examines a bed bug colony sample.

FEEDING STIMULANT. As it relates to feeding stimulants, three questions needed to be answered by the researchers: (1) What temperature(s) induce feeding? (2) What components of human blood serve as feeding stimulants? and (3) What are the effective concentrations?

Because bed bugs readily feed on blood, the effects of blood temperature on feeding were studied. Results showed more bed bugs would feed as temperatures rose, but they did feed at every tested temperature.

Several feeding stimulants then were considered (research done by Dr. Alvaro Romero), and more than most didn’t make the cut through the trials. Glucose, albumin, globulins, vitamins, cholesterol — none worked. Then a simple component became the ideal stimulant — ATP.

Extremely low ATP levels in saline induced bed bug feeding, therefore developing a low-cost stimulant that would keep the price of the overall bait down as well. “ATP is the energy source of our bodies,” DeVries said. “All you need is that and saltwater to induce feeding in bed bugs. Dr. Romero found a lot of things that didn’t work but with ATP in saline solution he was able to induce feeding. It’s very simple and we’ve used this in many ways in our lab for other purposes.

“One of the questions we get for testing is ‘How do you leave blood in the house?’ — and this is a critical step. We would never put blood in someone’s house as part of a bait, we would just use ATP and saltwater.”

ACTIVE INGREDIENT. A variety of factors had to be considered in the search for an active ingredient that would be ideal in a bed bug baiting system. According to DeVries, bed bugs are highly resistant to pyrethroids, and ingestible insecticides work effectively on many pests and are typically used at a lower rate than most sprays.

Because bed bugs would ingest the active ingredient, the research in this area (conducted by Angela Sierras) focused specifically on which insecticides worked and what were some of the sub- lethal effects that occurred after inges-tion.

Indoxacarb, a widely used and suc-cessful insecticide for use in cockroach baiting, had little to no effect on bed bugs. Fipronil and clothianidin both were able to achieve 100 percent mortality on bed bug males and nymphs. “Angela has done a lot of screening for bed bugs and most active ingredients she’s tested are effective,” he said.

Angela Sierras examines bed bugs under a microsope.

ATTRACTANT. The current stage of this project rests in this category — the search for the perfect bed bug attractant to make the baiting system ready for the industry.

“We don’t know exactly how bed bugs locate their hosts,” DeVries said. “We have to look at the choices a bed bug makes in response to CO2, heat and body odors.”

DeVries has been able to show that bed bugs only respond to heat over a very short distance (~ 1 inch). “We’re in the process of testing odors bed bug orient towards, with the idea of identifying specific com-pounds that bed bugs are attracted to. It’s really exciting work.”

ULTIMATE GOAL. DeVries said he’s enjoyed working on this interesting, highly collaborative project. “There are several people who are working on a number of parts of this project for several years now, and we have quite a large team committed to this project.”

He said the team is out to prove the doubters wrong. “Every place we go we get skeptics, people who think it won’t work or won’t put much faith in it — it’s a long-term project and we knew it would take a long time, but we’re making great progress and learning a lot about bed bugs in the process,” he said.

“The ultimate goal is to develop a functioning bait to put out in the field but for example if we identify odors that attract bed bugs and never develop a bait, these compounds will help us to build better monitoring devices and other products.”

DeVries added, “This project combines both basic and applied research, which we can use against bed bugs to improve management. We’re excited by what we’ve found so far and the potential impact of this project on bed bug management.”

The author is a Chicago-based contributing writer who can be reached at edemask@gie.net.

Bed Bug Control 101

Bed Bug Supplement - Bed Bug Supplement

When it comes to bed bugs, Jeff White, technical director of BedBug Central, said the often straightforward process of controlling these pests can be simple, but the journey to understand why we take the steps that we do can be challenging.

At NPMA’s 2016 Global Bed Bug Summit, White paved the way for subsequent speakers by covering bed bug basics. In addition, he provided important takeaways for industry veterans.

White, who has more than 10 years of experience as an entomologist, said what contributes to the U.S. bed bug epidemic is the public’s ignorance. “We’re busy in society and a lot of times if something doesn’t impact us directly, we’re not paying attention to it.” It’s the technician’s job to approach the problem with empathy, but to also know the basics of bed bug biology and behavior to assist in educating the client.

BIOLOGY. Note that bed bugs are about ¼ of an inch, oval-shaped, flat and reddish/brown. Many mistake bed bugs for ticks.

White noted that lab studies have found a bed bug life cycle at 64°F may take 60 days versus 14 days at 82°F.

All stages of bed bugs use blood as a food source, which they can get from humans, dogs and cats, birds and rabbits.

Bite symptoms typically show on exposed skin surfaces and are often in rows and clusters. White cautioned not to use bites to identify the problem. Bed bug bites can look like many other reactions. Studies show many people who are exposed to bed bugs will either show delayed or no symptoms at all. “Not reacting to bed bug bites is the ultimate curse,” White said.

THE SPREAD. Most bed bugs are associated with sleeping areas, which includes couches. White said when developing treat-ment protocols consider the distribution of infestations in an apartment. He stated that not all infestations need the same level of treatment:

Low: less than 20 bed bugs on an ini- tial service (70 percent of cases)

Moderate: 21-100 bugs (20 percent)

High: Over 100 bugs (10 percent)

Most service technicians can control low- level cases with relative ease; the problem is some companies handle high-level infestations the same as low-level ones. “How you handle a low-level infestation from a protocol perspective does not have to be as advanced as a high-level [one],” White said.

The public sees hotel rooms as a hotbed for bed bugs. White, however, reminded PMPs one of the most common infestation sources is used furniture.

INSPECTION AND DETECTION. When PMPs visually inspect for bed bugs, they often can be overlooked, especially in low-level infestations. White recommends a combination of visual inspection and active and passive monitors. To White, interception devices are key.

Four Phases of Infestation

From years of evaluating the resurgence of bed bugs in cities across the country, Jeff White, technical director of BedBug Central, suggests the following is a typical timeline of bed bug infestations for a city or region.

Phase 1: Bed bug reports are isolated, and mostly in hotels and apartments; very few people know about the infestations.

Phase 2: Bed bugs are starting to be reported in all residential environments (i.e., single-family homes, apartments, low-income housing, shelters) and the public is beginning to become aware of bed bugs; those directly impacted are most aware of the problem.

Phase 3: Bed bugs are widespread and becoming common in lower socio-economic settings; people who are not dealing with bed bugs are starting to pay attention.

Phase 4: Bed bugs begin showing up in public settings (i.e., offices, schools) and public hysteria is common.

Under-the-bed-leg interception devices will detect 95 percent of all infestations within two weeks. Next-to-the-bed-leg monitors will detect 80 percent within four weeks. “Take monitors and install them, check them periodically and you’ll find all those infestations that people aren’t reporting,” White said.

TREATMENT. There are many treatment options, and White said there is no “right” way. While heat treatment, fumigation, non-chemical approaches, pesticides and IPM can all work, it’s not about what you use but rather how you use it.

Giving customers a preparation sheet is a debatable approach, but White said consider getting rid of the initial prep sheet altogether. By having residents strip a bed or move around furniture in the room, White said PMPs lose control of the room now that it is configured differently. Instead of requiring residents to prep “just because,” evaluate the infestation first and then make recommendations on what to prepare based upon where the evidence tells you the bugs are hiding.

“Many professionals ask residents to prepare a room to save time, but how much time are you saving when you have a resident do some of these steps?” he asked. “Beyond not saving a lot of time, you are complicating the situation for yourself by having them move furniture around.”

Heat is a great way to treat for bed bugs, but White noted it involves a full day of work, so it can be costly. For companies that take an integrated approach to bed bug control, White said be aware of pesticide resistance. Rotate liquid residuals and choose products that have different active ingredients and modes of action. Combine dual-actives and single-actives with dust products. Also, use a vacuum or steamer and consider mattress encasements and monitors.